James S. Kirk & Co. v. United States

LITTLETON, Judge.

The question in this case is whether plaintiff is entitled to have included in invested capital for the fiscal year ending November 30, 1917, an amount for intangible assets acquired through expenditures for canvassing and advertising.

Plaintiff contends that the expenditures from 1900 to 1906 by its predecessor, the New Jersey corporation, developed intangible assets of great value which were acquired by the present corporation in 1908, and that the subsequent expenditures for somewhat similar purposes should be capitalized, and that the invested capital for 1917 should be…